If you work for or with a pharmaceutical company that has a Facebook page, then you are probably well aware of Facebook’s recent decision prohibiting pharmaceutical brands from disabling users’ ability to comment on brand posts, photos and videos. While branded pages solely dedicated to a prescription drug may continue to have the commenting functionality disabled (with Facebook’s approval), company, disease and patient-oriented pages must now allow commentary.
Prior to this decision, which went into effect August 15, pharmas were exempt from Facebook’s mandate that all pages allow for user commentary. This was done to protect pharma companies from any user comments that violate strict regulations set by the Food and Drug Administration (FDA). This includes comments about side-effects and comments deemed as off-label promotions— which means to promote the use of a medical devise or drug for an indication not approved by the FDA. (For instance, if a company has a branded page for an anti-depressant and a user comments that the drug also improved his cholesterol level). The FDA could hold the pharma responsible for such comments by issuing a citation to the company. Companies were also concerned about the FDA’s “fair balance” requirement that calls for product claims about a drug to be balanced with additional information about its risks.
While pharmas are having to adapt to the new change, by either removing their pages or monitoring them more closely, many in the industry understand that one of Facebook’s main features is its interactivity and encouragement of dialogue on pages. The organization that people are irked at isn’t Facebook, rather it’s the FDA, for their unwillingness to outline clear social media guidelines and/or policies.
For the past month, those following the situation closely have been waiting with abated breath to see the type of outcome the decision would result in, with many predicting that pharmas would remove their pages altogether.
However thus far, the change has not had the major effect that many thought it would have. WCG, a communications agency focused on health care, reported that out of 62 pharmaceuticals, only 11 have removed their pages. Most are modifying their pages and carefully monitoring comments to catch and delete any that might raise a red flag with the FDA, such as comments that reference a product or posts that offer medical advice. Also as mentioned above, product-specific pages, in which inappropriate comments are more likely to be made, may continue to be disabled.
In addition, there are other ways that pharma companies can acclimate themselves to the change. There is a “More Information” section at the bottom of walls that can be used to add important safety information that will always show at the bottom of the page. This eliminates companies having to include the same disclaimer in every single post.
Since users cannot mention a product name, even to ask questions, pharma companies should provide an alternative, such as a FAQ section or a ‘Contact Us with Product Questions’ form that users can fill out. They should also consider having a comment policy page that explains the types of comments that will be removed and the reasoning behind the removal as Pfizer does here.
Applications also have been developed that will help pharmaceutical brands with the change including Facebook AETracker which helps pharma companies track user comments on adverse drug reactions and product misinformation in real-time as well as the PharmaWall which allows administrators to manage what content is posted to their Facebook page.